Privacy is an article,
not a brochure word.
Two products, two jurisdictions, one company, one posture: name the article, name the officer, say what we encrypt and how long we keep it. If a privacy-conscious user can’t learn something new from this page, we’ve failed our own rule.
What Ebenworks is and isn’t the controller of.
Ebenworks is the company. Imali and Chingu are products operated under Ebenworks, each with its own governing statute and its own users.
- Imali (operated by Ebenworks) is the data controller for Imali users (SA merchants). Governing statute: POPIA.
- Chingu (operated by Ebenworks) is the data controller for Chingu users (Korean seniors and their families). Governing statute: PIPA.
- Ebenworks as a company processes only the marketing-site contact data and dispatch list described in §04 below.
- Where a product matures and earns its own legal entity, its data-controller status moves with it. Today, both are products under one company.
POPIA, by article.
Imali processes WhatsApp message metadata, transaction records, and (where the merchant supplies them) receipts and invoices. The relevant articles, with what they govern.
Information Officer. Named: Ebenezer Tarubinga (interim). Contact: ebenworks@ebstar.co. Registration with the SA Information Regulator filed; registration number will be printed here on receipt.
Right to correction / deletion. Reply delete me on WhatsApp. Records destroyed within 30 days; SARS-mandated retention windows excepted.
Cross-border transfer. Imali compute runs on Render in Frankfurt (eu-central-1). Data sub-processors sit across the US (Neon Postgres us-east-1, Upstash Redis, OpenAI) and a global edge (Cloudflare R2, default jurisdiction). Each cross-border flow is disclosed under POPIA s72(1)(a)+(b) in the live Imali privacy notice; merchant data classified as “personal information” (PI), not “special PI.”
Security safeguards. TLS 1.3 in transit. AES-256 at rest. HMAC-SHA256 on every inbound WhatsApp message. Keys rotate quarterly. K-anonymity ≥ 50 merchants on every aggregate query.
Notification of compromise. Information Regulator and the affected merchant notified within 72 hours of becoming aware of a reasonable belief of a compromise.
This site runs no Meta pixel, no Segment, no Hotjar, no Google Analytics. Logs are server-side, retained 14 days for security review only.
PIPA & AI Basic Act, by article.
Chingu processes voice (a biometric under PIPA Art 23), conversation transcripts, and welfare-officer dashboard interactions. The articles below govern each.
개인정보 보호책임자 / Data Protection Officer. Named: Ebenezer Tarubinga (interim, English-language contact). Korean-language DPO will be named alongside the Korean entity registration (in progress). Contact: ebenworks@ebstar.co.
Sensitive information.Voiceprint is biometric. Separate, opt-in, revocable consent. Chingu’s wake word runs on-device; no audio leaves the phone until the senior says Chingu-ya.
Destruction. Voice clips and transcripts auto-delete after 90 days unless the senior (or family with separate consent) opts to keep them.
AI identity disclosure. First-call script (Korean): “안녕하세요, 친구야 입니다. 저는 사람이 아니라 AI입니다. 언제든지 ‘사람과 통화’라고 말씀하시면 담당자에게 연결됩니다.” Translation: “Hello, this is Chingu. I’m an AI, not a person. Say ‘connect to a person’ any time and a caseworker will be reached.”
Inside Korea. All processing on KR-region infrastructure (KISA-aligned providers). No cross-border transfer. Backup region named on the procurement contract.
Korean entity registration in progress; PIPA filing follows entity registration. Registration number will be printed here on receipt. KISA certification (privacy & security) targeted at first-pilot launch (Q3 2026).
What we collect on this site.
Almost nothing. The marketing site exists to be readable, not to harvest.
contact@ebstar.co. Not stored anywhere else. Deleted within 90 days of thread close. POPIA Art 24 / PIPA Art 21.next/font, so your browser makes no request to Google. No analytics SDK is embedded.The not-yet list.
Voice playbook Rule 04. We say what isn’t there, plainly.
No POPIA registration number to print on a poster. Registration with the SA Information Regulator filed; the number lands here when it lands.
No KISA certification stamp for Chingu. The certification is targeted to the first paid municipal pilot, not before.
No external DPA with the dispatch provider yet. The newsletter list is small enough that we manage it directly; an external DPA is on the list before the list is.
No third-party privacy audit. We will commission one before the first paid Chingu pilot ships.
One inbox per jurisdiction.
Per-product privacy questions go to the product’s inbox. General-purpose privacy questions (or anything about this page) go to the company inbox.